proximate cause. Chamberlain Estate of Chamberlain v. City of White Plains, 960 F.3d 100 (2d Cir. 2020): Sack and Hall, writing for the panel, reinstated claims for unlawful entry, excessive force, and supervisory liability against officer-defendants who fatally shot a U.S. Marine veteran with mental illness after the officers forced their entry into his apartment. United States v. Napout, 963 F.3d 163 (2d Cir. 2020): Sack, writing for the panel, affirmed convictions of two International Federation of Association Football (FIFA) officials for multiple counts of fraud conspiracy, concluding that the convictions rested upon permissible domestic applications of the federal wire fraud statute and rejecting defendants' arguments that the honest services fraud statute is unconstitutionally vague as applied to them. In re Bernard L. Madoff Investment Securities LLC, 976 F.3d 184 (2d Cir. 2020): Sack, writing for the panel, held that transfers of fictitious profit from the Madoff Ponzi scheme were not "for value" for purposes of the fraudulent transfer provision of the Bankruptcy Code, so bankruptcy trustee for Bernard L. Madoff Investment Securities LLC was entitled to recover those funds. Compania Embotelladora Del Pacifico, S.A. v. Pepsi Cola Company, 976 F.3d 239 (2d Cir. 2020): Sack, writing for the panel, held that an "exclusive bottler appointment" contract between Pepsi Cola and one of its bottlers in Peru contained no clear statement of perpetuity and was thus terminable at will. Sleepy's LLC v. Select Comfort Wholsesale Corp., 909 F.3d 519 (2d Cir. 2018): Sack, writing for the panel, held that mattress manufacturer's allegedly defamatory statements to retailer's agents could satisfy the publication element of a slander claim, and that remand was necessary for the district court to consider whether the retailer consented to the utterance of those allegedly slanderous statements. Peterson v. Islamic Republic of Iran, 876 F.3d 63 (2d Cir. 2017): Sack, writing for the panel, vacated in part a district court order dismissing claims by judgment creditors against Iran and Iran's Ministry of Intelligence and Security; Sack held that certain of the judgment creditors were not bound by a settlement agreement releasing Iran's central bank from liability, and that the bond proceeds held by a Luxembourg bank on behalf of Iran's central bank were not immune from execution under the Foreign Sovereign Immunities Act. Perez v. City of New York, 832 F.3d 120 (2d Cir. 2016): Sack, writing for the panel, held that fact issues precluded summary judgment as